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White Papers

When we realize some aspect of physical environment regulation is widely misunderstood, and/or of such importance to the ASC industry it should be explained to all, we put an explanation in writing. Most introductory topics are here for public sector consumption, others more specialized and specific are available for a fee.

CMS holds ASCs solely responsible for compliance with all applicable NFPA standards. The problem is that no-one has bothered to tell organizations that a large number of NFPA-regulated issues require specific processes and documentation to maintain compliance through time. This paper establishes the basic parameters and scope of NFPA “operational requirements” for inspection, testing, and maintenance throughout an ASC.

It is common knowledge that CMS currently requires compliance with the 2000 edition of NFPA 101®, the Life Safety Code® (LSC); but seemingly few understand the LSC references more than a dozen others, that together define what is necessary to achieve and maintain compliance. This primer describes the interaction between various NFPA documents most influential in terms of ASC design, construction, occupancy, and maintenance.

The good news is that power strips are definitively allowed in ASCs; the bad news is CMS has so many strings attached you may not want then. This paper condenses and reorganizes the “Categorical Waiver” announced by CMS on 9/26/2014, to make as much sense of it as we can.

Many existing ASCs are stunned to learn the location of their waiting room does not comply with CMS/NFPA requirements for separation from other entities, even though they may have been approved by Local and State authorities or even CMS. This brief paper organizes the pertinent considerations and interpretations to clarify the requirement and its basis.

Seldom does so simple a requirement create so many headaches; as does wrongly located medical gas shutoff valves, first identified during a LSC survey. This short paper brings together specifically applicable sections of the NFPA standard, and provides narrative to make sense of it all.